{"id":39639,"date":"2026-08-04T09:57:13","date_gmt":"2026-08-04T08:57:13","guid":{"rendered":"https:\/\/figsflow.com\/uk\/?p=39639"},"modified":"2026-08-04T09:59:58","modified_gmt":"2026-08-04T08:59:58","slug":"uk-money-laundering-regulation-2026","status":"publish","type":"post","link":"https:\/\/figsflow.com\/uk\/uk-money-laundering-regulation-2026\/","title":{"rendered":"UK Money Laundering Regulation (MLR) Amendment: What is Changing in 2026?"},"content":{"rendered":"\t\t
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The Money Laundering and Terrorist Financing Regulation (MLR) 2026 amendment SI 2026\/621 came into force on 06\/30\/2026. They do not replace the Money Laundering<\/a>, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). They amend it in about fifteen targeted places, and they also reach into Schedule 3A to the Terrorism Act 2000 and Schedule 9 to the Proceeds of Crime Act 2002 so that the definitions of the regulated sector stay in step.<\/p>

The amendments retune specific obligations practitioners have long debated, like thresholds and due diligence, helping firms feel assured about their ongoing compliance.<\/p>

The direction of travel is towards proportionality, but proportionality cuts both ways. Some obligations have been relaxed. Others have been extended, and a few of the extensions are easy to miss because they sit in schedules rather than in the body of the Regulations. For most accountancy, bookkeeping and tax practices, the practical work is a documentation exercise: firm-wide risk assessment, threshold tables, country risk lists, client onboarding templates and staff training all need to be brought into line with the amended text.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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The Instrument at a Glance<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Item<\/th>\n Detail<\/th>\n <\/tr>\n <\/thead>\n
Full title<\/td>\n The Money Laundering and Terrorist Financing (Amendment) Regulations 2026<\/td>\n <\/tr>\n
Reference<\/td>\n SI 2026\/621<\/td>\n <\/tr>\n
Enabling powers<\/td>\n Sections 49 and 54(2) of, and Schedule 2 to, the Sanctions and Anti-Money Laundering Act 2018<\/td>\n <\/tr>\n
Parliamentary route<\/td>\n Draft affirmative under section 55(5)(d), SAMLA 2018<\/td>\n <\/tr>\n
Laid before Parliament<\/td>\n 25\/03\/2026<\/td>\n <\/tr>\n
Made<\/td>\n 09\/06\/2026<\/td>\n <\/tr>\n
Principal commencement<\/td>\n 30\/06\/2026 (21 days after making)<\/td>\n <\/tr>\n
Deferred: cryptoasset correspondent EDD<\/td>\n 01\/02\/2027 (new regulation 34A)<\/td>\n <\/tr>\n
Deferred: cryptoasset change in control<\/td>\n Partly 30\/06\/2026; remainder 25\/10\/2027 (Schedule 6B)<\/td>\n <\/tr>\n
Extent<\/td>\n England and Wales, Scotland, Northern Ireland<\/td>\n <\/tr>\n <\/tbody>\n <\/table>\n\t\t<\/div>\n\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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Euro Thresholds Are Now Sterling Thresholds<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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Every euro figure in MLR 2017 has been replaced with a sterling figure. Most convert on a 1:1 basis, so \u20ac10,000 becomes \u00a310,000. The point is administrative rather than philosophical: firms no longer have to pick an exchange rate, document why they picked it, and defend the choice to a supervisor two years later.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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The New Threshold Table<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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MLR 2017 Provision<\/th>\n Subject<\/th>\n Old figure<\/th>\n New figure<\/th>\n <\/tr>\n <\/thead>\n
Reg 13(4)(b)(ii)<\/td>\n Letting agents \u2013 monthly rent trigger<\/td>\n €10,000<\/td>\n £10,000<\/td>\n <\/tr>\n
Reg 14<\/td>\n High value dealers, casinos, auction platforms, art market participants<\/td>\n €10,000<\/td>\n £10,000<\/td>\n <\/tr>\n
Reg 15(3)(b)<\/td>\n Exclusions<\/td>\n €10,000<\/td>\n £10,000<\/td>\n <\/tr>\n
Reg 27(1)(b)<\/td>\n Occasional transactions \u2013 transfers of funds<\/td>\n €1,000<\/td>\n £800<\/td>\n <\/tr>\n
Reg 27(2)<\/td>\n Casinos<\/td>\n €15,000<\/td>\n £12,000<\/td>\n <\/tr>\n
Reg 27(3)<\/td>\n Occasional transactions \u2013 general<\/td>\n €10,000<\/td>\n £10,000<\/td>\n <\/tr>\n
Reg 27(5) and (7)<\/td>\n Specified transactions<\/td>\n €2,000<\/td>\n £2,000<\/td>\n <\/tr>\n
Reg 27(7A)(ii) and (7C)<\/td>\n Art market participants and linked transactions<\/td>\n €10,000<\/td>\n £10,000<\/td>\n <\/tr>\n
Reg 27(7E)<\/td>\n Cryptoasset transfers<\/td>\n €1,000<\/td>\n £800<\/td>\n <\/tr>\n
Reg 38(1)<\/td>\n Electronic money \u2013 monetary limits<\/td>\n €150<\/td>\n £150<\/td>\n <\/tr>\n
Reg 38(2)<\/td>\n Electronic money \u2013 redemption and withdrawal<\/td>\n €50<\/td>\n £50<\/td>\n <\/tr>\n
Regs 64C(4) and 64G(1)(b)<\/td>\n Cryptoasset transfer information<\/td>\n €1,000<\/td>\n £800<\/td>\n <\/tr>\n <\/tbody>\n <\/table>\n\t\t<\/div>\n\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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Why Did Some Figures Not Convert 1:1?<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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Three figures moved down rather than across. The \u20ac1,000 transfer-of-funds threshold became \u00a3800, the \u20ac15,000 casino threshold became \u00a312,000, and the \u20ac1,000 cryptoasset transfer figure became \u00a3800. HM Treasury explains that a flat 1:1 conversion would have raised the sterling threshold above the level the Financial Action Task Force expects, which would have put the UK offside on its international commitments at precisely the wrong moment. The UK’s mutual evaluation is on the horizon, and thresholds are the kind of detail assessors check first.
For accountancy firms, the practical consequence is small but real. Any threshold hard-coded into an onboarding checklist, a client acceptance form, or an AML platform configuration needs to be checked against the table above rather than assumed.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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Enhanced Due Diligence Has Been Narrowed<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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This change has the broadest impact, influencing a wide range of areas, yet it is frequently misinterpreted or overlooked in its significance.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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High-Risk Third Countries Become FATF Call for Action Countries<\/h3>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t
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Regulation 33(1)(b) previously required enhanced due diligence for any business relationship or relevant transaction involving a person established in a “high-risk third country”. That term was defined by reference to both FATF public lists: the “Call for Action” list and the “Jurisdictions under Increased Monitoring” list, commonly called the grey list.From 06\/30\/2026, the trigger is narrower. Mandatory under regulation 33(1)(b) EDD\u00a0\u00a0now applies only where a party is established in an FATF call for action country, defined as a jurisdiction on the FATF’s High-Risk Jurisdictions subject to a Call for Action list as it has effect from time to time. Regulation 39(4), on reliance, was amended in the same way.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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Following the FATF plenary on 19\/06\/2026, that list contained three jurisdictions: the Democratic People’s Republic of Korea, Iran and Myanmar. The increased monitoring list, by contrast, ran to twenty-two jurisdictions.
Here is where firms need to be careful. Removing the grey list from the automatic trigger does not remove it from the analysis. HM Treasury’s advisory notice of 22\/06\/2026 is explicit that relevant persons must continue to take FATF mutual evaluations into account as a geographical risk factor under regulation 33(6)(c). It must still apply enhanced due diligence and enhanced ongoing monitoring wherever they identify a high risk of money laundering or terrorist financing. A firm that quietly deletes twenty-two countries from its risk model and documents nothing in their place has not become more proportionate. It has created a gap that a monitoring visit will find.
The defensible approach is to restructure country risk in two tiers: a mandatory EDD<\/a> tier tied to the call for action list, and a risk-assessed tier that captures increased monitoring jurisdictions, the UK National Risk Assessment, sanctions exposure and any sector-specific intelligence, with a documented rationale for the treatment applied to each.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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\u201cUnusually Complex or Unusually Large\u201d<\/h3>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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The old wording required EDD for transactions that were “complex or unusually large”. In sectors where most transactions look complex on their face, that produced blanket application and very little risk differentiation.
The amended wording, inserted at regulations 19(4)(a)(i)(aa), 19A(4)(a)(i)(aa) and 33(1)(f)(i), is “unusually complex or unusually large in each case given the nature of the transaction”. The word “unusually” now qualifies both limbs, and the assessment is expressly relative to what is normal for that type of transaction.
The other limbs of regulation 33(1)(f) are untouched. A transaction with no apparent economic or legal purpose, or an unusual pattern of transactions, still triggers EDD. This is a refinement of an existing test, not a new exemption, and firms should be able to show how their revised approach to complexity was arrived at.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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CDD Triggers for Letting Agents & Art Market Participants<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Regulation 27 has been amended so that the transaction-based CDD triggers for letting agents and art market participants align with those already applying to high value dealers. The word “occasional” has been inserted before “transaction”, and the linked-transaction language has been redrafted to cover a transaction “whether executed in a single operation or in several operations which appear to be linked”. The monetary trigger sits at \u00a310,000.
For firms advising art market participants, this closes an argument that had been running for some time about how the \u00a310,000 test applied to a series of related sales. It now reads consistently with the high-value dealer provisions, which means the established HMRC guidance on aggregation is a better reference point than it used to be.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t

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Pooled Client Accounts: New Duties on Both Sides<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Pooled client accounts have been a live problem: banks treated them as either automatically low risk or too difficult, and firms with a legitimate need struggled to open them. The 2026 Regulations decouple pooled accounts from the simplified due diligence framework and replace it with a risk-based structure, in new paragraphs (10) to (18) of regulation 29. These apply to new pooled accounts opened on or after commencement.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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What The Bank Must Now Do:<\/h3>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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